On the other hand, the taxpayer also receives valuable safeguards.
For example, the IRS is prohibited from levying on property with respect
to the unpaid tax while the offer is pending, for thirty days following
rejection of the offer, and while a timely appeal is pending.12 Thus, the OIC procedure offers benefits that make it an attractive option for
a delinquent taxpayer.
While the OIC procedure is a creature of statute, looking only to
the statute and accompanying regulations will not yield a complete
picture of the procedure’s operation. Specific details on how the IRS
executes the OIC procedure are contained in the Internal Revenue
Manual.13 The Manual also describes four key policy objectives of the
OIC procedure:
Effect collection of what can reasonably be collected at the earliest
possible time and at the least cost to the government.
Achieve a resolution that is in the best interests of both the individual
taxpayer and the government.
Provide the taxpayer a fresh start toward future voluntary compliance
with all filing and payment requirements.
Secure collection of revenue that may not be collected through any
other means.14